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AHRQ stated that assessing kidney function and damage involves the use of several biomarkers, with serum creatinine and other serum indicators employed to estimate the estimated glomerular filtration rate (eGFR)

CMS computes an ACO's shared savings payment by applying the final sharing rate to the ACO's savings on a first dollar basis (meaning the final sharing rate is applied to the ACO's full total savings amount), with the payment subject to a cap that is equal to 20 percent of the updated benchmark ( 425.610(e)(2))

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A few commenters expressed concerns that the proposed HEBA conflates risk adjustment with the goals of Shared Savings Program benchmarking policy and is thus unlikely to achieve its stated goals. These commenters encouraged CMS to develop policies that advance health equity without impacting benchmark adjustments

This surprises people who assume injections are always more expensive